Template — not legal advice. This policy is a starting draft. Items marked [CONFIRM: …] must be checked against how the app actually works and then removed. Consider having an attorney review it before launch.

Privacy Policy

Effective date: [CONFIRM: EFFECTIVE DATE, e.g. January 1, 2027]

This Privacy Policy explains how Thomas R&D LLC (“Thomas R&D,” “we,” “us”) collects, uses, and shares information when you use our mobile app [APP NAME] (the “App”) and this website, thomasrnd.com (together, the “Services”). We try to collect as little as possible, and we never sell your personal information.

1. Summary

2. Information we collect

Information you provide

Information collected automatically

We do not collect precise location, contacts, photos, or advertising identifiers for tracking, and the App does not show third-party ads. [CONFIRM: true for the final build.]

3. Subscriptions and payments

Subscriptions to the App are sold and processed by Apple (App Store) or Google (Google Play). Your payment details are handled entirely by Apple or Google under their own privacy policies. Thomas R&D LLC does not receive or store your credit card number or other payment card details. We receive only the information needed to verify your purchase and subscription status (for example, a transaction identifier, product purchased, and renewal or expiration date).

4. How we use information

We use the information described above to:

We do not sell your personal information, share it for cross-context behavioral advertising, or use it to build advertising profiles.

5. How we share information

We share information only in these limited cases:

6. Children’s privacy

The App is intended for parents, guardians, and other adults. It is not directed to children under 13, and children are not the intended users of the App. Although the App’s subject matter is elementary school math, its content is written for adults who want to help a child learn.

We do not knowingly collect personal information from children under 13, consistent with the U.S. Children’s Online Privacy Protection Act (COPPA). We ask that parents not enter a child’s personal information (such as name, photo, or school) into the App. If you believe a child under 13 has provided us with personal information, please contact us at admin@thomasrnd.com and we will promptly delete it.

[CONFIRM: In App Store Connect, do not place the App in the Kids category, and set the age rating accordingly; in Google Play’s Target Audience section, select adult age groups only. If the App will ever be used directly by children, this section and the App’s data practices must be revised.]

7. Data retention

We keep personal information only as long as needed for the purposes described in this policy — for example, while you have an account or active subscription — and as required to meet legal, tax, or accounting obligations. Support emails are retained for up to [CONFIRM: e.g. 2 years]. When information is no longer needed, we delete or de-identify it.

8. Your choices and data deletion

Depending on where you live (for example, Washington, California, or the European Economic Area), you may have additional rights under local law. We will honor applicable requests and will not discriminate against you for exercising your privacy rights.

9. Security

We use reasonable administrative, technical, and physical safeguards to protect information, including encryption in transit. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

10. Where data is processed

Thomas R&D LLC is based in the United States. Information may be processed and stored in the United States or other countries where our service providers operate.

11. Changes to this policy

We may update this policy from time to time. If we make material changes, we will update the effective date above and, where appropriate, notify you in the App. Your continued use of the Services after a change means the updated policy applies.

12. Governing law

This Privacy Policy is governed by the laws of the State of Washington, United States, without regard to its conflict-of-laws rules.

13. Contact us

Thomas R&D LLC
Email: admin@thomasrnd.com